Interpretation ID: nht95-2.60

TYPE: INTERPRETATION-NHTSA

DATE: April 28, 1995

FROM: Thomas L. Wright -- Acting Manager, MVS Customer Services, State Of New Jersey, Department Of Law And Public Safety, Division Of Motor Vehicles

TO: Dorothy Nakama -- Office of Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 6/27/95 LETTER FROM JOHN WOMACK TO THOMAS L. WRIGHT (A43; PART 567; STD. 1) ALSO ATTACHED TO 7/13/92 LETTER FROM PAUL JACKSON RICE TO JEFFREY PUENTES.

TEXT: Dear Ms. Nakama:

Recently we have had an inquiry from a motorcycle accessory distributor who wants to become a manufacturer of motorcycles. The motorcycles that they intend to manufacture will be assembled with engines from one manufacturer and chassis from another. These engines and chassis have their own certificates of origin. Since New Jersey does not license manufacturers, we have suggested that these vehicles be titled as reconstructs. This company does not want to pursue reconstructed titling as they feel t hat it devalues their product and because of problems incurred with other jurisdictions accepting the title.

We are attempting to gather information on how an enterprise becomes a recognized manufacturer, issue certificates of origin, and assign VIN's. We would appreciate any information you can provide us with concerning these matters.